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Editorial - Improving Truck Safety Without A Single, Additional Regulation

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by Dave Osiecki
Senior Vice President for Policy & Regulatory Affairs
The American Trucking Associations

Most have heard the outcome of MAP-21, the latest highway law, for the Federal Motor Carrier Safety Administration.  FMCSA has said repeatedly that MAP-21 requires it to complete 29 new safety regulations within 27 months.   FMCSA will be challenged to complete them within that timeframe.  And, no matter when they do, the trucking industry will be challenged to comply with another set of new safety rules.  What if I told you, though, that truck safety could be significantly improved without a single, additional regulation, but rather with a single change to the longstanding Federal-State Inspection program known as MCSAP (the Motor Carrier Safety Assistance Program commonly referred to by its acronym)?  Allow me to briefly describe how this is possible.  

Before doing so, let’s start with a simple quiz.  Assume for a minute you were fortunate enough to inherit a whopping $3.5 million from a wealthy Uncle…let’s call him Charlie.  In learning this great news, you also discover that old Uncle Charlie had this fortune in two investments with the same investment firm--$3.0 million in an investment with a 1% guaranteed rate of return; and $500,000 in an investment with a 3% guaranteed rate of return.  Other than questioning your generous Uncle’s investment IQ, what would you do with these investments?  The answer’s simple, right?  You’d quickly move the $3.0 million into the 3% guaranteed investment to maximize your return.  If not, you may want to stop reading here.  And, yes, I realize some of you are saying you’d find a different investment in order to find a guaranteed 6 or 7% return, and a small portion of you are saying ‘let’s go to Vegas baby.” But humor me and read on…

So what does this quiz have to do with more truck safety without more regulations?  A great deal, because the numbers I chose above (3.0 million and 500,000, and the 3 to 1 difference in the rate of return), are the 2012 numbers from the MCSAP program.  Under MCSAP in 2012, FMCSA funded the 50 States to perform a total of about 3.0 million Roadside Inspections of trucks and drivers, and further funded the States to conduct about 500,000 Traffic Enforcement stops of truck drivers operating unsafely (e.g., speeding, unsafe lane change, etc.) which then triggered some type of limited inspection of either the driver’s paperwork or the truck.  So, in 2012, the number of FMCSA-funded Roadside Inspections far outpaced the number of Traffic Enforcement stops.

Yet, FMCSA’s own analysis published in April 2011 (and recently updated in April 2013) on the safety effectiveness of these two MCSAP enforcement interventions (Roadside Inspections and Traffic Enforcement stops coupled with a limited inspection) demonstrates that the benefits (i.e., the rate of return) are 3 to 1 in favor of Traffic Enforcement stops coupled with a limited inspection (called simply “Traffic Enforcement” for the remainder of this piece).  In other words, according to FMCSA, Traffic Enforcement prevents about three times more truck crashes (and saves 3 times more lives) than do Roadside Inspections (as measured on a per 1,000 interventions basis).

So, let’s go back to the Uncle Charlie scenario for a moment.  If you inherited the MCSAP program and discovered it was investing in 3.0 million Roadside Inspections with a guaranteed safety return of 1%, and 500,000 Traffic Enforcement stops with a guaranteed safety return of 3%, what would you do?  Pretty simple, right?  

Take a look at the following data from the Intervention Effectiveness table contained FMCSA’s 2011 data-driven analysis[1]

Benefits Associated with Various Activities

Total Benefits

U.S.

Benefits per

1,000

Interventions U.S.

Crashes Avoided-Roadside Inspection

8,493

3.64

Crashes Avoided-Traffic Enforcement

9,555

13.14

Total

18,048

(TE to RI ratio is 3.60 to 1)

Injuries Avoided-Roadside Inspection

5,474

2.34

Injuries Avoided-Traffic Enforcement

6,159

8.47

Total

11,633

(TE to RI ratio is 3.61 to 1)

Lives Saved-Roadside Inspection

321

0.14

Lives Saved-Traffic Enforcement

362

0.50

 

 

(TE to RI ratio is 3.57 to 1)

(TE to RI ratios in table above were added by ATA)

The high water mark for MCSAP Traffic Enforcement interventions was in 2006 at 900,000.  That number dropped by more than 43% to only 510,000 in 2012, in favor of more Roadside Inspections (which went from 2.3 million in 2006 to just over 3 million in 2012).[2]   This leads to a reasonable question—why is FMCSA investing MCSAP dollars in a manner that, by its own data-driven analysis (conducted under the Government Performance & Results Act requirements for “resource allocation” purposes), is far less effective at truck crash prevention than it could be?   

The answer is more complicated than shifting from one ‘investment’ to the other as in the Uncle Charlie scenario.  The answer lies in a common challenge facing many federal programs.  They quickly develop a sincere, well-meaning constituency which becomes vested in the program as it was originally developed.  The longer the program goes on, the more vested the constituency becomes, and the more difficult it is to change.  This is the case even when it becomes clear that data-driven change would result in better outcomes.  In this case, the better outcome is greater truck and highway safety through more effective allocation of resources.  That is, more Traffic Enforcement activity aimed at unsafe drivers, which will also generate data to target motor carriers who facilitate or encourage unsafe behavior.

I am a strong advocate for MCSAP.  It’s been a success story, and has made a positive contribution to driver and truck safety since it began almost 30 years ago.  I am also a strong advocate for bringing data-driven change to MCSAP to bring more balance to the interventions in order to make it a far more effective program for the benefit of professional drivers, the industry, the motoring public, and highway safety.  And, this positive safety change can be accomplished without a single, additional regulation.



[1] See Table 5 in FMCSA’s April 2011 “Intervention Effectiveness” report at  http://www.fmcsa.dot.gov/facts-research/research-technology/report/Intervention-2007.pdf